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CORRESP
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CORRESP

 Peter M. Carlson

Executive Vice President and

 Chief Accounting Officer

 pcarlson@metlife.com

April 11, 2013

 Mr. James B.
Rosenberg

 Senior Assistant Chief Accountant

 Division of Corporation Finance

 United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

Re:
MetLife, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2012

Filed February 27, 2013

File No. 001-15787

 Dear
Mr. Rosenberg:

 This letter sets forth the response of MetLife, Inc. (the “Company”) to the comments contained
in your letter dated March 28, 2013, regarding the Company’s Report on Form 10-K filed on February 27, 2013.

In response to your comments, we have reproduced your comments below in boldface, italic type and set forth our response immediately
below each comment.

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Estimates

Goodwill, page 89

1.
Please provide us proposed disclosure to be included in future filings to clarify why the Department of Financial Service inquiry into the use of captive or
off-shore reinsurers and the National Association of Insurance Commissioners’ (“NAIC”) study of the use of captives would affect the value of your retail annuities goodwill. Please clarify if these inquiries may have a future effect
on your results of operations.

 Mr. James B. Rosenberg

 Securities and Exchange Commission

 April 11, 2013

 Page
 2

 Management Response:

 Proposed Disclosure

 In future periods when these activities are disclosed, we will
add the following disclosure within “Management’s Discussion and Analysis of Financial Condition and Results of Operations – Summary of Critical Accounting Estimates – Goodwill”:

Within the Retail Annuities reporting unit, most variable annuity guaranteed minimum benefit rider risk has historically been reinsured
within a wholly-owned captive reinsurance subsidiary. As permitted, we calculate regulatory capital for that entity using less conservative assumptions than would be required to calculate minimum capital for this business by the ceding domestic
insurance subsidiary. In prior period goodwill impairment analyses, management’s assessment was that a buyer would base its appraisal on the assumption that it would be able to continue to maintain these reinsurance arrangements indefinitely.
In the third quarter of 2012, as captive reinsurers came under increased regulatory scrutiny, we believed that a buyer as of September 30, 2012 would no longer take the view that replicating such a regulatory capital structure using captives
would be viable indefinitely and, therefore, would require a higher capital charge for the Retail Annuities reporting unit.

Clarification

 For a discussion
of potential effects of these inquiries on the Company’s results of operations, please see “Business – U.S. Regulation – Holding Company Regulation – Insurance Regulatory Examinations” (page 19 of the Company’s
2012 Form 10-K) and “Risk Factors – Regulatory and Legal Risks – Our Insurance and Brokerage Businesses Are Highly Regulated and Changes in Regulation and in Supervision and Enforcement Policies May Reduce Our Profitability and Limit
Our Growth” (page 38 of the Company’s 2012 Form 10-K). In future periods when these activities are disclosed, we will add a cross-reference to such discussion in “Management’s Discussion and Analysis of Financial Condition and
Results of Operations – Summary of Critical Accounting Estimates – Goodwill.” If increased regulatory scrutiny of the use of captive or off-shore reinsurance arrangements results in diminished viability of such arrangements, the
Company’s U.S. GAAP results of operations and regulatory capital and surplus could be adversely affected, and appropriate disclosure would be included in future filings.

 Results of Operations

 Consolidated Results

Year Ended December 31, 2012 Compared with the Year Ended December 31, 2011, page 95

2.
Please provide us proposed disclosure to be included in future filings to address the following:

•

 Please break out the $1.2 billion charge between the amount related to DAC, the amount related to reserves and the amount related to intangibles.

•

 Please identify the key assumptions that changed as a result of the global review and the factors that caused these assumptions to change.

 Mr. James B. Rosenberg

 Securities and Exchange Commission

 April 11, 2013

 Page
 3

•

 For the $526 million reflected in net derivative gains (losses), please clarify where this is reflected in the table on page 96.

•

 You provide a breakdown of the derivatives gains (losses) in the table on pages 96 and 98. Please clarify the specific factors which caused
significant fluctuation from period to period in the nonperformance risk factor and explain why those factors changed.

•

 Your discussion on pages 96 and 98 relating to the change in market and other risk factors focuses on the net change. Please revise to clarify
the specific factors that caused the significant fluctuation from period to period in the market and other risk factor on a gross basis. In addition, please provide a breakdown of the factors included in market and other risks. The breakdown in the
bullets beginning on pages 96 and 99 only appears to address the market factors.

 Management Response:

 In future periods when these activities are disclosed, we will include the following disclosure, adjusted to reflect actual results
for the period, in “Management’s Discussion and Analysis of Financial Condition and Results of Operations – Result of Operations – Consolidated Results”:

Results for 2012 include a $1.2 billion ($753 million, net of income tax) charge associated with the global review of assumptions related
to DAC, reserves and certain intangibles, of which $526 million ($342 million, net of income tax) was reflected in net derivative gains (losses) within the “market and other risks in embedded derivatives” component of net derivative gains
(losses). Of the $1.2 billion charge, $1.1 billion ($740 million, net of income tax) and $77 million ($50 million, net of income tax) related to reserves and intangibles, respectively, partially offset by $57 million ($37 million, net of income tax)
associated with a review of assumptions related to DAC.

 As a result of the global review of assumptions, changes were made to
policyholder related assumptions, Company specific assumptions and economic assumptions. The most significant impacts related to policyholder surrenders, anticipated future dividend scales and general and separate account returns.

Changes to policyholder related assumptions resulted in reserve increases with corresponding favorable DAC changes of approximately $700
million ($455 million, net of income tax) for the year ended December 31, 2012. The most significant contributor to the increase in reserves was the change in the assumption regarding policyholder surrenders. The policyholder surrenders for our
variable deferred annuity block have been trending lower as there are fewer new annuity products available and as the value of the rider guarantees has increased over time relative to actual equity performance and low interest rates. We also
decreased our general account earned rate as well as the expected future performance in the separate accounts due to current and anticipated low interest rates for an extended period of time, resulting in an acceleration of amortization and an
increase in insurance liabilities of approximately $240 million ($156 million, net of income tax). In addition, we also updated the future cash flows and corresponding dividend scales associated with the closed block as a result of current and
anticipated low interest rates for an extended period of time, contributing to the acceleration of DAC amortization of approximately $115 million ($75 million, net of income tax).

See Note 1 of the Notes to the Consolidated Financial Statements for a discussion of the Company’s impairment charge of $77 million
($50 million, net of income tax) resulting from actual persistency experience being less favorable than what was assumed when the asset was acquired.

 Mr. James B. Rosenberg

 Securities and Exchange Commission

 April 11, 2013

 Page
 4

 Commencing with the Company’s Form 10-Q filing for the quarter ended March 31, 2013, we will
include substantially the following disclosure (additional proposed disclosure in bold), adjusted to reflect actual results for the period, in “Management’s Discussion and Analysis of Financial Condition and Results of Operations –
Results of Operations – Consolidated Results”:

 The table below presents the impact on net derivative gains (losses)
from non-VA program derivatives and VA program derivatives:

Years Ended
December 31,

Change

2012

2011

(In millions)

 Non-VA program derivatives

 Interest rate

$
271

$
2,536

$
(2,265
)

 Foreign currency exchange rate

(426
)

171

(597
)

 Credit

(105
)

173

(278
)

 Equity

1

6

(5
)

 Non-VA embedded derivatives

(61
)

17

(78
)

 Total non-VA program derivatives

(320
)

2,903

(3,223
)

 VA program derivatives

 Market risks in embedded derivatives

4,303

(2,332
)

6,635

 Nonperformance risk on embedded derivatives

(1,659
)

1,822

(3,481
)

 Other risks in embedded derivatives

(1,344
)

(791
)

(553
)

 Total embedded derivatives

1,300

(1,301
)

2,601

 Freestanding derivatives hedging embedded derivatives

(2,899
)

3,222

(6,121
)

 Total VA program derivatives

(1,599
)

1,921

(3,520
)

 Net derivative gains (losses)

$
(1,919
)

$
4,824

$
(6,743
)

 The unfavorable change in net derivative gains (losses) on non-VA program derivatives was $3.2 billion
($2.1 billion, net of income tax). This was primarily due to long-term interest rates increasing in the current period but decreasing in the prior period, unfavorably impacting receive-fixed interest rate swaps, long interest rate floors and
receiver swaptions. These freestanding derivatives are primarily hedging long duration liability portfolios. The weakening of the U.S. dollar and Japanese yen relative to other key currencies unfavorably impacted foreign currency forwards and swaps,
which primarily hedge certain foreign denominated bonds. Additionally, the narrowing of credit spreads in the current period compared to widening in the prior period unfavorably impacted credit default swaps hedging certain bonds. Because certain of
these hedging strategies are not designated or do not qualify as accounting hedges, the changes in the estimated fair value of these freestanding derivatives are recognized in net derivative gains (losses) without an offsetting gain or loss
recognized in earnings for the item being hedged.

 The unfavorable change in net derivative gains (losses) on VA program
derivatives was $3.5 billion ($2.3 billion, net of income tax). This was due to an unfavorable change of $3.5 billion ($2.3 billion, net of income tax) related to the change in the nonperformance risk adjustment on embedded derivatives, a
favorable change of $514 million ($334 million, net of income tax) on market risks in embedded derivatives, net of the impact of freestanding derivatives hedging those risks, and an unfavorable change of $553 million ($359 million, net of income
tax) on other risks in embedded derivatives. Other risks relate primarily to the impact of policyholder behavior and other non-market risks that generally cannot be hedged.

 Mr. James B. Rosenberg

 Securities and Exchange Commission

 April 11, 2013

 Page
 5

 The $3.5 billion ($2.3 billion, net of income tax) unfavorable change in
nonperformance risk from a gain of $1.8 billion ($1.2 billion, net of income tax) in 2011 to a loss of $1.7 billion ($1.1 billion, net of income tax) in 2012 was due to changes in the Company’s own credit spread and the impact of capital market
inputs on the variable annuity guarantees. The Company calculates nonperformance risk as the change in the embedded derivative discounted at the risk adjusted rate (which includes the Company’s own credit spread) less the change in the embedded
derivative discounted at the risk free rate. The nonperformance risk loss of $1.7 billion ($1.1 billion, net of income tax) in 2012 was due to a decrease in the Company’s own credit spread, the increase in the long-term risk free interest rate,
and the increase in key equity index levels. The nonperformance risk gain of $1.8 billion ($1.2 billion, net of income tax) in 2011 was due to an increase in the Company’s own credit spread, the decrease in the long-term risk free interest
rate, and the decrease in key equity index levels.

 When equity index levels decrease in isolation, the guarantees
become more valuable to policyholders, which results in an increase in the undiscounted embedded derivative liability. Discounting this unfavorable change by the risk adjusted rate yields a smaller loss than by discounting at the risk free rate,
thus, creating a gain from including an adjustment for nonperformance risk.

 When the risk free interest rate decreases
in isolation, discounting the embedded derivative liability produces a higher valuation of the liability than if the risk free interest rate had remained constant. Discounting this unfavorable change by the risk adjusted rate yields a smaller loss
than by discounting at the risk free rate, thus, creating a gain from including an adjustment for nonperformance risk.

When the Company’s own credit spread increases in isolation, discounting the embedded derivative liability produces a lower
valuation of the liability than if the own credit spread had remained constant. As a result, a gain is created from including an adjustment for nonperformance risk. For each of these primary market drivers, the opposite effect occurs when they move
in the opposite direction.

 The foregoing favorable change of $514 million ($334 million, net of income tax) is
comprised of a $6.1 billion ($4.0 billion, net of income tax) unfavorable change in freestanding derivatives that hedge market risks in embedded derivatives, which was more than offset by a $6.6 billion ($4.3 billion, net of income tax) favorable
change in market risks in our embedded derivatives.

 The primary changes in market factors are summarized as follows:

•

 Long-term interest rates increased in the current period but decreased in the prior period and contributed to an unfavorable change in our freestanding
derivatives and favorable changes in our embedded derivatives.

•

 Key equity index levels improved in the current period but decreased in the prior period, and equity volatility decreased in the current period but
generally increased in the prior period. These changes contributed to an unfavorable change in our freestanding derivatives and a favorable change in our embedded derivatives.

•

 Changes in foreign currency exchange rates contributed to an unfavorable change in our freestanding derivatives and favorable changes in our embedded
derivatives.

 Mr. James B. Rosenberg

 Securities and Exchange Commission

 April 11, 2013

 Page
 6

 The foregoing $553 million ($359 million, net of income tax) unfavorable change in
other risks in embedded derivatives was primarily due to:

•

 Periodic updates to actuarial assumptions, such as changes in policyholder behavior and mortality, which resulted in an unfavorable year over year
change in the valuation of the embedded derivatives. The primary driver of the change related to a reduction in lapse assumptions in the current year.

•

 Periodic refinements in valuation models to better reflect product features and the projected capital markets environment, which resulted in a
favorable year over year change in the valuation of the embedded derivatives.

•

 Periodic updates to the mapping of policyholder funds into groups of representative indices, which resulted in an unfavorable year over y